Request for Interpretation Regarding Licensee Recordkeeping

HPPOS-204 PDR-9111210348

See the memorandum from J. W. N. Hickey to W. L. Axelson dated May 19, 1987.

Although computer storage of required records is a broad issue, it appears that, in general, records maintained on computer media would be appropriate. An example, where computer storage is not appropriate, is the situation in which a copy of a document is required to be held. The health physics position was written in the context of 10 CFR 20.311, but it also applies to "new" 10 CFR 20.2006.

Guidance was requested on whether records maintained only on computer media and not in hard copy satisfy the Commission's requirements for record-keeping. Computer storage of required records is a broad issue, and NRC is not able to address all situations that may arise for all licensees. In general, however, records maintained on computer media would meet the requirements of the regulations in many cases, provided the records are available for inspection and can be produced in hard copy promptly upon request.

Computer recordkeeping would not be acceptable for those requirements that specify a copy of a document must be held [see, for example, 10 CFR 20.311 (d) (7) and 10 CFR 20.2006 (d), specifically Section III.B.5 of Appendix F to 10 CFR 20.1001-20.2401. Note: 10 CFR 30.39 (d) (1) is no longer applicable]. It would be the licensee's responsibility to take such measures as are necessary to ensure the reliability of the records, including protection from loss, tampering, alteration, or destruction, as is the case with any required records.

Such measures should include storing separately one other copy (backup) of the computer storage medium for the time required.